Modern Slavery statement

Sustainable Homes’ Modern slavery and human trafficking statement

Sustainable Homes is a subsidiary of Hastoe Housing Association. As such our modern slavery policies are in line with those of our parent company with some variations due to the different purpose of the business.

Modern Slavery and Human Trafficking Statement

Sustainable Homes is a subsidiary of Hastoe Housing Association. As such our modern slavery policies are in line with those of our parent company with some variations due to the different purpose of the business.

Introduction and Commitment from the Board

Sustainable Homes is fully opposed to, and committed to preventing, modern slavery and human trafficking within our organisation and throughout our supply chains.

We have put in place a Modern Slavery and Human Trafficking Policy to demonstrate our commitment to acting ethically and with the highest standards of integrity in all our business dealings and relationships. This is in line with our ongoing alignment of Sustainable Homes’ policies with the Sustainable Development Goals (SDG’s). We see this statement as being relavant to: Goal 8 Decent Work and Economic Growth and Goal 10 Reduced Inequality

We are committed to developing, implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere within our business or in our relevant supply chains.

We will never knowingly deal with any business involved in modern slavery or human trafficking.

Purpose and scope of this statement

This statement is made on a voluntary basis with reference to section 54(1) of the Modern Slavery Act 2015. It relates to the year ended 31 March 2018. It applies to all legal entities that form part of the Hastoe Group.

This statement sets out the steps we have already taken and intend to take, to minimise the risk of modern slavery and human trafficking in our business activities and within our relevant supply chain.

Organisational structure and business function

Sustainable Homes is a not-for-profit research, accreditation and consultancy body registered as a subsidiary of Hastoe Housing Association.

Areas of Risk – Our Business

We estimate the risk of modern slavery and human trafficking occurring within our own business as being low. Sustainable Homes has robust policies and procedures in place for carrying out background and identity checks on all new employees. We ensure that all staff are eligible to work in the UK and we only pay salaries directly into employees’ personal bank accounts. We pay our interns in line with the rates for the London Living Wage.

Areas of Risk – Our Supply Chain

Sustainable Homes works with commercial entities and third party suppliers. Our procurement policy is in line with the Hastoe Procurement Policy and Procedure. We conduct due diligence checks on all our suppliers before contractual stage.

All Sustainable Homes contracts contain the following clause to be included in all new procurement contracts where we receive goods or services.

“The Contractor acknowledges that as an organisation carrying out business in the UK it is required to comply with the Modern Slavery Act 2015. The Contractor warrants that it does so and that it will publish a Statement about the steps it is taking to ensure its operations and relevant supply chains are free of modern slavery and human trafficking”.

All contractors and supplies, whatever their level of turnover, should warrant that neither it nor any of its officers, employees, nor so far as it is aware, any sub-contractor or other persons associated with it, have been convicted of any offence involving modern slavery and human trafficking.

Should any contractor not be able to provide the required warranties, Sustainable Homes will need to take a view on their commitment to having a business free from modern slavery and human trafficking.

Future Actions – Procurement and Supply Chain

Sustainable Homes, in line with its alignment of policies with the Sustainable Development Goals will be reviewing existing contractual relationships to ensure that suppliers are in line with core SDGs (to be confirmed).

Future Actions – Our Business

We will raise employee awareness about modern slavery issues through our intranet and encourage them to report concerns and ensure that these are acted upon and reported to the Board.

We will deliver training to all employees so that everyone understands the signs of modern slavery and human trafficking, and knows what to do if they suspect it is taking place within the workplace, in our homes or within our relevant supply chain.

We will review our approach to recruiting agency workers.

We will continue to review and update relevant internal policies, procedures and practices, taking effective and proportionate steps to ensure there is no modern slavery or human trafficking in our business.

We will continue to build on our approach to modern slavery and human trafficking and annually update this statement to reflect the best practice possible in these evolving changes.

Working Practices

The following existing policies and procedures contribute to preventing modern slavery and human trafficking:

Modern Slavery & Human Trafficking Policy

Procurement Policy and Procedure

Anti-Fraud Policy

Recruitment Policy and Procedure

Code of Conduct

Safeguarding Policy and Procedure

Maintaining Standards of Probity

Whistle Blowing Policy and Procedure

The Sustainable Development Goals

Performance Indicators

We will consider the steps we are taking to ensure that modern slavery and/or human trafficking is not taking place within our business or supply chain to be effective if:

We receive no reports from employees, residents, the public, or legal or government agencies, to indicate that modern slavery or human trafficking practices have been identified.

Approval

This statement was approved by the Hastoe Board on 3 May 2018 and will be reviewed annually. This statement will be circulated to the Sustainable Homes Board for approval.

Please contact us should you have any questions relating to statement.